Myrtle Macomber (plaintiff) owned 2,200 shares of stock in the Standard Oil Company of California (Standard), a publicly traded company. Standard experienced increased growth in its value and issued a 50 percent stock dividend. As a result, Macomber received an additional 1,100 shares of Standard stock. Pursuant to the Revenue Act of September 8, 1916 (Act), c. 463, 39 Stat. 756, et seq., the United States government (defendant) sought to tax Macomber on the 1,100 shares of stock that she received. Macomber sued the government, asserting that the stock dividend was not taxable income. The district court ruled in favor of Macomber. The United States Supreme Court granted certiorari.